Privacy Notice

FLOCAR SERVICIOS JURÍDICOS, S. C., ARMANDO FLORES CRUZ and/or FRANCISCO CARPIO CAMPOS, henceforth “FLOCAR LAW”, with registered address 296 Paseo de la Reforma , 38th floor, Colonia Juárez, C. P. 06600, Cuauhtémoc, Mexico City, Mexico, E-mail address info@flocarlaw.com, responsible for collecting, storing, using and protecting personal data inform you as follows: Information provided by their Owners through any means of communication be it digital, on-site, telephone, mobile phone, will be subjected to this Privacy Notice and the Terms and Conditions that rule over the relationship between them and FLOCAR LAW. IF YOU DO NOT AGREE WITH THIS PRIVACY NOTICE, PLEASE AVOID SHARING ANY INFORMATION OF ANY TYPE BY ANY MEANS WITH FLOCAR LAW. This Privacy Notice is applicable to all the data Owners, people located in the United Mexican States. We do not accept or acknowledge any jurisdiction or legislation different to that applicable in Mexican territory. This Privacy Notice is only applicable to owners of data who provide us with such data.

PERSONAL DATA

In order to carry out the aims and tasks described in this Privacy Notice we will use personal identification, contact, work and asset/property data. Additionally, we may collect individual information from third parties that are at the same time ruled to comply with legislation applicable to the matter of privacy, which will be added to the information you provide for our Data Base. Besides personal data previously mentioned, for the purposes informed to you in this Privacy Notice, we will use data which are considered sensitive and require special protection —particularly financial data or information, business information, keeping in mind that it is a general rule to have written express consent from the Holder before handling any sensitive personal data through his/her electronic or autograph signature or any other mechanism established with this purpose.

PRIMARY PURPOSES

Personal data provided by you, even sensitive data, will be used for all the purposes linked to the juridical or contractual relationship we establish and honor with you, considering the effect of the above mentioned relationship as the Primary Purpose. In deeper detail, the Primary Purpose, in most of premises, will have to do with contacting the holder, providing him/her with information, delivering documents to him/her as well as protecting his/her legal interest and more concretely, any other purpose derived from the relationship the Holder(s) may have established with FLOCAR LAW.

SECONDARY PURPOSES

Personal data we collect from you will be used for the following purposes not necessary to the requested services but which will allow us to provide better assistance: Using information belonging to the Holder to inform him/her about our activities, services, products, programs and/or promotions we may consider of the Holder(s)’s interest, derived from the relationship or bond there is with each one of them. Creating and using added information about the Holder that is not individually identifiable in order to understand mire about the common features and interests of multiple Holders, for example, prospects/leads, clients, employees, suppliers, etc; as well as issuing statistics, opinions and strategies based on scattered data belonging to the Holder(s) in order to understand the behavior of our market through native studies or third parties to whom Holder(s)’s data may have been transferred for any treatment, always under rule of this Privacy Notice. Using the Holder’s information in order to execute or honor any contract with us or any Terms regarding the relationship or bond between us and/or the Terms of Use of our website, Social Networks, Premises, or to provide access or release information that we out of good faith consider necessary for our compliance of applicable law; Sharing the Holder’s Information with any third party who acquires the business or shares related to that information, for which, the new responsible party is forced to write and issue a new Privacy Notice in compliance applicable law; the Treatment of the Holder’s Information and the sharing of it with our partners and subcontractors in charge of managing any of our activities on our behalf or as we consider it necessary in order to maintain, provide or improve services and communication. If you do not want any of your personal data to be treated this way, you can state your refusal during the following five days after hiring any services from FLOCAR LAW through any of the means of contact mentioned in the first part of this Privacy Notice. The refusal to the use of your personal data for these purposes cannot lead to our refusal to provide our services and products as requested or hired, although in some cases such refusal will make it impossible for us to provide the hired services.

SAFETY

We only collect information we deem reasonably necessary to the serving of the legitimate interest of our business and in order to comply with our own legal obligations and duties. We protect Information Holders in all that regards their released information, under the principle of confidentiality, complying with the ruling standards of protection in effect in this industry and in compliance with the Federal Law on the Protection of Personal Data Held by Private Individuals and its Regulation. Disregarding the lack of a “guaranteed safety” on the internet and outside, we make commercially reasonable efforts to ensure that the collection, treatment, storage and guarding of information are all performed in compliance with all the applicable legislation. For the moment, each one of our means of collection of information including our Website, Social Networks, E-mail addresses, WhatsApp , among others, use a variety of security measures aimed at protecting information, in order to avoid non-authorized use by anyone within or without the company, including the use of coders and other administrative, technical and physical security measures established by the pertaining law. Thus, we are protected from the loss, damage, misuse, interception or sabotage to any confidential information, such as confidential numbers, online requests and financial/banking information. Our practices in communication systems, software and physical/electronic data beses are designed in order to help us keep the authenticity integrity and confidentiality of all collected data. It is worth noting that disregarding our use of all the necessary means to maintain the safety of data and information, whenever it is transmitted through third parties (service providers), we cannot guarantee the safety of Information during such transmissions by any means.

WHAT WE WON’T DO WITH INFORMATION

Selling or leasing your information to third parties outside FLOCAR LAW, or allowing our partners to sell or lease any Information to third parties outside the reach of FLOCAR LAW’s control, past or present companies; Acting as an agency of evaluation of services and activities with/for Holders or providing any type of information related to the social or economical status, purchasing power, way to be, reputation, personal features or way of living of the Holder, to any agency of service evaluation. 
TRANSFERENCES
We hereby inform you that your personal data may be shared within or outside the country with our Allies, Subcontractors and/or Suppliers in order to maintain, provide or improve our services, as well as for any of the purposes previos described. Unless specifically provided by law or by our contractual obligations and duties, we will be able to release personal information if there is a legal request by means of a judicial order or by request of a government authority, or if in good will we consider that the releasing of such information is necessary or even advisable. Such situations may include: honoring, maintaining or trying to make our contracts honored with our clients or any Holder in order to protect this/her right or properties or those of our partners, or whenever we have strong reasons to believe that releasing such information is necessary in order to identify, contact or execute legal action against anyone who harms or intends to harm or interfere with the ownership of our rights as well as our products or brand, be it intentionally or otherwise, or when any person might be harmed by such activities. In the case of data transferal in which express consent is required, we will obtain such consent in advance.

ACCESS, RECTIFICATION, CANCELATION AND OPPOSITION

You are entitled to know which of your personal data we have and we store, how we use it and the conditions under which we use them (access). Likewise, you are fully entitled to request any correction to that personal information in case it has not been properly updated, it is inaccurate or incomplete (rectification); you are also entitled to request for us to delete it fully from our records and data bases when you consider it is not being used in compliance with the principles, duties and obligations established by regulation (cancellation); as well, you are entitled to oppose the use of your personal data for specific purposes (opposition). These rights are known as “ARCO”. In order to execrase any of these ARCO rights, you must present a request by contacting the managers of FLOCAR LAW, via E-mail at: info@flocarlaw.com or directly in our headquarters located at 296, Paseo de la Reforma 296, 38th floor, Colonia Juárez, C.P. 06600, Alcaldía de Cuauhtémoc, Mexico City, stating: (i) name and address of the Holder or any other means to communicate our answer, (ii) proof of identity, or if applicable, a legal representation of the Holder, (iii) a clear accurate description of the personal data on which you intend to exercise the previously mentioned rights, and (iv) any other element or document that will make it easier to find such data. We will contact the Holder of the information in a maximum of 20 days from the date we received the request of access, rectification, cancellation or opposition, in order to state the final resolution to his/her request so that, if it is valid, it will be honored within the following 15 days after the date of our response. The terms mentioned hereby can be extended only once for a period identical in length, as long as the particular circumstances of a case justify the lengthening. However, we will continue to email you about the bond in effect between you and FLOCAR LAW until it comes to an end. Holders will be able to opt out of contact information including E-mail address, instant messaging, facsimiles and telephone calls. We keep “do not call” and “do not send any mail” lists. Requests asking us to add you to these lists are resolved within a maximum of 20 business days after the date of reception; if the request is deemed valid, it will be effective within the following 15 days after our response. Both periods can be extended over an identical period. Any Client can opt out for certain information by emailing us or contacting FLOCAR LAW’s headquarters as stated at the beginning of this Privacy Notice. You can always revoke the consent you may have given us when processing your personal data. However, it is important for you to know that it is not in all cases that we can respond to your request or come to conclusions immediately, since it is possible that a certain legal obligation may make it compulsory for us to continue handling your personal data or that your personal data may have become public information as a consequence of any of the services acquired. Likewise, you must consider that for main purposes, the revocation of your consent will cause us not to be able to continue to provide you with our services or may cause our relationship to you come to an end, which will be informed to you through the resolution sent to you in compliance with the times stated hereby. In order for you to limit the use and release of personal data, we offer the following means: Registration in the Public Record under the orders of The Federal Consumer Protection Office in order to avoid marketing spam or promos by companies selling goods and/or services. For further information about this registration, you can consult PROFECO’s official website or contact them directly.

COOKIES, WEB BEACONS AND INVISIBLE PIXELS

We hereby inform you that we may use “cookies”, “Web Beacons” and “Invisible Pixels” in our website through which it is possible to monitor your behavior when browsing the internet in order to give you better service and a better user experience when browsing our website, as well as in order to offer you new products and services based on your own preferences. Personal data we get through this tracking technology are the following: time you browse, length of your stay on our website, sections enquired and other third party websites visited before visiting ours. We do not use cookies to store any passwords or sign in information or passwords. Cookies do not show your identity unless you choose to share it. Your browser can be programmed to notify you whenever a cookie is installed in your search engine, so that you can decline or delete cookies that may have been installed in your browser. Some features of our Websites may not work or work slowly if cookies are refused. Our Website may use third party services such as servers or hosting for our promos but we might as well use our own. As for third party providers, these may install cookies on your computer if you click on their advertisement. Third party cookies are used to trace if you have reached their landing page by clicking on their advertisement. Cookies derived from ads do not contain any of your personal information. We do not control these cookies and they may not comply with the rules we have established for our own cookies. We and our advertisement servers will be able to use invisible pixels, best known as visitor counters in our Website in order to count how many people visit certain websites. Information collected by invisible pixels is used and reported in the added information without the need to use any personal data. This information may be used for the purpose of improving websites, advertisement and its content as well as to refine advertisement in our own Website as well as that of third parties on the internet, whenever it is related to our commercial image. In our Websites we do not collect personally identifiable information pertaining Holders, unless it is given to us voluntarily and knowingly. When you enter our Websites, we ask for your authorization to collect information such as name, address, telephone number, age, date of birth, place of birth, E_mail address. The main purpose of getting your E-mail address is to send information about FLOCAR LAW and its products and/or brands, and/or to exchange information pertaining the bond and relationship between you and FLOCAR LAW as well as Promos and/or Programs that may eventually exist. Like many other websites, ours collects non-personal information related to the Holders, such as information about software they use (for example IP Address, browser version, and OS) as well as added information (E.g. number of websites visited in a row) automatically in order to analyze web traffic and user trends; this way, we can define the content and services of your interest so we can adapt to the needs of the relationship we establish with each information Holder. This type of information won’t be linked to your identity nor to your personal information. Our Websites contain links and/or related websites that lead the Holder to other websites, some of which are not affiliated to us or controlled by us. Once you abandon our Websites, each new website you visit may have its own Privacy Notice and Terms of Use. Your interaction with such websites won’t be subjected to rules established in this Privacy Notice and its Terms of Use. Therefore, your use of such third party websites will be at your own peril. When it comes to the use of websites, we do make an effort to create and keep best practices regarding technical, administrative and physical safety and security, as well as to use other appropriate protection systems in order to stay in control of information we keep so that it will be used as it is authorized to and to keep it from being altered or destroyed. Third parties may install cookies in your computer if you click on their advertisement. Third party cookies are used to trace if you reached their landing pages by clicking on their advertisement on other websites. Cookies derived from ads do not contain any personal information. We do not control these cookies and they may not follow the rules established for our own cookies. We and our ad servers may use invisible pixels, best known as visitor counters, in our Website to keep record of how many people visit certain websites. Information collected by invisible pixels is used and reported in the added information without the need to use any personal information. This information may be used to improve websites, advertisement and its content as well as to refine advertisement in our own Website as well as other third party websites on the internet. For further information about our advertisement server or if you would like to know your options on keeping us from using your personal information to send you promos, please send FLOCAR LAW a message to info@flocarlaw.com

AVAILABILITY, PRIVACY NOTICE AND CHANGES

The Privacy Notice in effect at the time you share information will be applied to any exchange. However, we can change its validity or deem it expired, in which case we will let you know through: (i) visible notices in our premises and work places; (ii) brochures available in our premises or work places; (iii) our Websites; (iv) letting you know via E-mail, for which it will be possible to refuse any use of information in advance as established in the new Privacy Notice. Please, make sure you read our Privacy Notice any time you share information; do it more frequently if you are greatly concerned about the use we will make of your information.

CONFIDENTIALITY OF INFORMATION

Whenever Personal information is requested, you will only share it with us, unless it is stated otherwise. If the Personal Information of any Holder is shared with partners in business or sponsors, the Holder will be notified before the information is collected or transferred. If the Holder does not want such information to be disclosed or shared, he/she will be able to withdraw from requesting specific services. FLOCAR LAW will not be responsible for the confidentiality of any additional information given by its Holder, including information given through forums or newsletters, nor will it be responsible for information obtained through cookies described in this Privacy Notice.

CONTACT WITH INFORMATION HOLDERS

When an information Holder calls our contact centers or contacts us over the internet, facsimile or any other means of contact to consult or request any service, assistance or meetings from FLOCAR LAW as well as about any existing or future bond between FLOCAR LAW and the Holder, we will require certain information such as name, home address, e-mail address and telephone number in order for us to be able to respond to the request. The Holder must all all times ask and record the request number or confirmation of registration code when placing a request, changing or cancelling it or its registration on our records. Information collected as part of this process of registration will be used exactly as this Privacy Notice describes it. We currently use services by third party providers to send any communication or message. The provider is not permitted nor enabled to use the Holder’s contact data in any way different to the sending of communications related to information derived from the bond between the Holder and us, given these providers know this Privacy Notice.

CONTACT DATA

For any issue related to this Privacy Notice and your personal data, feel free to contact us via email to info@flocarlaw.com, or by visiting our headquarters at 296 Paseo de la Reforma 296, 38th floor, Colonia Juárez, C. P. 06600, Alcaldía de Cuauhtémoc, Mexico City, Mexico. In case you have any further enquiries about the handling of personal data, you can consult the Federal Institute of Access to Public Information (in Spanish, INAI) at www.inai.org.mx NOTE: information disclosed here is property of FLOCAR LAW. The sharing or duplication of this document and/or information contained in it is strictly forbidden by FLOCAR LAW. All rights reserved © 2019 FLOCAR LAW.